A Wall of Silence

Home , AVAX, Carillion, Interserve

A WALL OF SILENCE:

THE CONSTRUCTION SECTOR'S RESPONSE TO MIGRANT RIGHTS IN QATAR AND THE UAE EXECUTIVE SUMMARY 1

INTRODUCTION 3

THE COMPANY SURVEY 4

FINDINGS 4

DISCUSSION OF THE 16 CORPORATE RESPONSE

RECOMMENDATIONS 18

FULL COMPANY LIST 19 EXECUTIVE SUMMARY

An estimated 7% of the world’s workforce is spurred by the Qatar World Cup has resulted in a employed in the construction sector and the concerted focus on the industry and its business industry is expected to account for 15% of global partners from international institutions, govern- economic output by 2030. Qatar and the UAE are ments, media and civil society. These actors will witnessing remarkably rapid infrastructure continue to shine a spotlight where the industry development, boosted by the 2022 World Cup refuses to do so. and the 2020 Dubai World Expo respectively. The responses we did receive reveal the wide Global inequality is perhaps at its starkest in the gulf of understanding and commitment between construction of gleaming skyscrapers and mas- pioneering companies and a long tail of laggards. sive stadiums by migrant workers in the pursuit of Several companies are taking meaningful steps decent livelihoods. Exploitation of the majority to demonstrate the actions they are taking to migrant workforce in both Qatar and the UAE has improve safeguards for their migrant workforce, been well documented, but the situation for including Vinci (QDVC),2 Multiplex, Salini workers has been slow to improve and planned Impregilo, Laing O’Rourke, Interserve reforms widely criticized for being insufficient. and Carillion.

The abuses that migrant workers are subject to, Transparency on human rights issues has been including high recruitment fees, non-payment an important driver of progress in other sectors. of wages, and restricted mobility, traps them in It generates examples of best practice that can exploitative situations. Earlier this year, the media be shared publicly with others and replicated, and reported an Indian worker's suicide on a building drives accountability such that civil society, site in Qatar, cementing concerns over the investors and others can hold companies to their desperate situations migrant construction workers stated actions, or call them out for inaction. face if subject to unscrupulous employment practices.1 It is therefore disappointing that companies involved in the construction of World Cup stadiums Despite the spotlight on these abuses, our did not respond, including Al Balagh Trading & outreach to 100 construction companies has Contracting, Cimolai, Galfar Al Misnad, HBK found a shocking lack of transparency on the Contracting Company, J&P Avax SA, steps they are taking to address them. Only Joannou & Paraskevaides (Overseas), Mid- 22 responded to our survey on the subject (17 mac and Porr. The lack of response represents construction contractors, 4 project management/ a missed opportunity to demonstrate the actions engineering consultants and 1 developer). A they are taking to adhere to the Workers’ Welfare review of these companies’ websites reinforces Standards of Qatar’s Supreme Committee for the magnitude of omission when it comes to Delivery & Legacy. migrant rights in the construction sector. Just 39% have publicly available human rights It is similarly disappointing that regional construc- commitments and only 17% refer to any tion heavyweights with active projects in Qatar international standards. Just 3% have an explicit and the UAE – Arabtec, BK Gulf (a subsidiary commitment to the rights of migrant workers. of UK-headquartered Balfour Beatty), Habtoor Leighton Group, and Al Jaber Group – did not The 78 non-responding companies cannot rely on respond, despite the three former companies re- a wall of silence to escape scrutiny. The attention ceiving the UAE’s 2016 Taqdeer Award for excel- to the human-rights performance of the sector lence in labour relations.

1 https://business-humanrights.org/en/qatari-subsidiary-of-eta-star-ascon-group-failing-to-pay-migrant-workers-leaving-them-stranded-as- the-gulf-country-struggles-to-juggle-its-ambitions-for-the-2022-world-cup-with 2 VINCI (QDVC) operates in Qatar through QDVC, a Qatari Shareholding Company incorporated under the Law of Qatar since April 2007. Qatar Diar Real Estate Investment Company is 51% shareholder in the company and VINCI (QDVC) Construction Grand Projects is the shareholder of the remaining 49%.

1 Recent national attention to migrant workers’ compliance is subsequently monitored through rights in the Gulf has focused on driving improve- audits and ‘worker engagements’. The risks in- ments in health and safety, worker accommo- herent in accepted business models and complex dation and payment of wages. Now it is time for supply chains, however, cannot be resolved by concerted action in other critical areas such as companies acting in isolation: collective industry- fair recruitment, freedom of movement, worker wide efforts will also be needed. voice, and supply chain accountability. In each of these areas our outreach identifed examples of Some companies have also demonstrated action that other companies can follow. welcome engagement with international trade unions. Given that freedom of association is not For example, on freedom of movement, Vinci permitted within Qatar and the UAE, this can (QDVC) and Laing O’Rourke provide secure, be an important way to provide a degree of civil personal storage compartments at their accom- society oversight. Salini Impregilo has signed an modation facilities so that migrant workers have agreement with Building and Woodworkers In- sole custody of their passports. On recruitment, ternational (BWI) and Italian construction unions seven companies stated that they follow the to promote and respect the fundamental human employer pays principle with regards to recruit- rights of its workers worldwide, and has allowed ment fees. Laing O’ Rourke, Multiplex, Salini BWI to visit its worker accommodation in Qatar. Impregilo, SNC-Lavalin and Vinci (QDVC) said that they ensure migrant workers are reimbursed Committed and concerted action by the con- by the company or recruitment agency in the struction industry holds the potential to prevent event that they have been made to pay fees. exploitation and drive genuine improvements in the lives of millions of workers around the world. Another six companies stated that they would terminate their business relationships with recruit- While our outreach has identified some promising ing agencies that violate their terms. Carillion, leading examples, the entire sector has a long Laing O’Rourke and Salini Impregilo pointed to way to travel to fulfill its human rights t can draw important lessons a global policy on freedom of association and to responsibilities. I providing workers in their Gulf operations with from sectors that have long been scrutinized for alternative means of expression and collective supply chain risk, such as the apparel, food and organising through worker welfare committees. electronics industries. Within Europe, the UK’s Modern Slavery Act has A significant challenge facing the industry is the played an important role in kick-starting action by complexity of its supply chains. As the head the sector 4 t is striking that of the 22 responses of the UK’s Chartered Institute of Building has . I we received, 11 are from companies acknowledged: “[T]he global trend towards out- headquar sourcing and cut price contracting makes it easy tered in Europe where the influence of has been felt more strongly. for main contractors to duck out of their responsi- the Act bilities.” 3 Conversely, only three companies headquartered in the Gulf responded and none headquartered in In that vein it is encouraging that some frms are Asia (we approached companies based in China, taking steps to strengthen accountability down India, Japan, Malaysia and South Korea). There the supply chain. Interserve has instituted a is an urgent need to strengthen the competitive Worker Welfare Procedure that requires subcon- advantage for construction firms from all regions tractors and suppliers to pre qualify on the basis - to take a responsible approach to the recruitment of their employee welfare practices; their and employment of migrant workers.

3 The Chartered Institute of Building (CIOB), 2015. Modern Slavery: The Dark Side of Construction. Available at: https://policy.ciob.org/ wp-content/uploads/2016/02/CIOB-Research-The-Darkside-of-Construction.pdf. 4 The Act requires every organisation with a global annual turnover of £36 million with operations in the UK to produce a slavery and human trafficking statement for each financial year. View the BHRRC MSA registry here: https://business-humanrights.org/en/uk-modern- slavery-act-registry

22 Business partners and civil society actors should migrant workers and drawing attention to press for increased transparency from compa- discrepancies between reporting and nies, rewarding those that take a responsible implementation and company inaction. approach to the recruitment and employment of

Companies should: Adopt a public human rights Take urgent action to protect Ensure workers have access commitment and conduct migrant workers in key risk to individual and collective robust due diligence. areas. grievance mechanisms.

INTRODUCTION

An estimated 7 percent of the world’s workforce construction labour in the Gulf (see Annex 1). is employed in the construction sector, an indus- Workers often fall victim to: try that represents US$ 9 trillion globally and is expected to account for 15% of global output by ● Excessive debt incurred through high 2030. Migrant workers form the lifeblood of the recruitment fees workforce, “essential to provide the fexible supply ● Unequal, late, or non-payment of wages of labour needed to meet volatile demand…and or illegal deductions 5 reduce shortages when activity expands rapidly.” ● Appalling living conditions ● Treacherous working conditions Construction in the Gulf is no diferent in its re- ● Denial of freedom of movement liance on migrant workers, and the sector is grow- ● Denial of freedom of association and ing rapidly. The total value of projects planned assembly across the Gulf States was valued at US$ 2 ● Minimal enforcement of the labour law trillion in May 2016, having grown by an average ● Limited or no access to recourse to alter annual rate of 5% over the last five years. Qatar their plight has the fastest growing construction market in the ● Forced labour world,6 boosted by the infrastructure development for the 2022 World Cup. Dubai is ramping up its construction activities ahead of the World Expo Under the 2011 United Nations Guiding Principles 2020. on Business and Human Rights, companies have a responsibility to ensure that human rights are While the region has had a long-standing reliance being respected in their direct operations and in on migrant labour – the Gulf States were col- their supply chains. While international bodies lectively host to 22 million workers in 2013 - the and civil society have called for action from Gulf governments to fulfll their state duty to protect international reach, physical scale and demand workers’ rights and institute labour reform, con- for migrant labour on these projects are unprec- struction companies involved in the building of edented. International concern over migrant fagship projects have not been held to account workers’ rights has grown as a result, particularly for the treatment and working conditions of their with regards to the exploitative nature of trans- migrant workforce. Business & Human Rights national recruitment routes and the Gulf’s kafala Resource Centre's outreach was (sponsorship) system. therefore designed to draw attention to the conduct of companies and the of A slew of reports have documented the human human rights performance the sector as-a-whole. rights risks and abuse associated with migrant

5 Green, B., 2015. CIOB Perspectives: An Analysis on Migration in the Construction Sector. Available at: https://www.ciob.org/sites/ default/files/CIOB%20research%20-%20Analysis%20on%20Migration%20in%20the%20Construction%20Sector_1.pdf 6 Global Construction Perspectives and Oxford Economic (2013). Global Construction 2025. Available at: http://bit.ly/2ge5t6k 7 Kafala is the system of worker ‘sponsorship’ that governs the recruitment, employment and residency of migrant workers the Gulf. For a full explanation see Migrant Rights, 2015. Understanding Kafala: An Archaic Law at Cross Purposed with Modern Development. Available at: https://www.migrant-rights.org/2015/03/understanding-kafala-an-archaic-law-at-cross-purposes-with-modern-development/.

3 THE COMPANY SURVEY

In 2016, Business & Human Rights Resource We contacted 55 companies in relation to Qatar Centre invited 100 construction companies to re- and 45 companies in relation to the UAE. spond to questions on their approach to protecting the rights of migrant workers in their Qatar and The analysis is inclusive of the responses re- UAE operations. We launched the survey in rec- ceived by November 21, 2016. We drew on guid- ognition of the minimal attention to the corporate ance published by Building and Wood Workers responsibility to respect human rights within the International (BWI), Human Rights Watch and Gulf context and to increase transparency around our own knowledge and experience to analyse construction firms' operations. Business the responses. In doing so we identified 10 key transparency is a key driver of improvement: it areas enables the sharing of best practice and strength- of focus on which we based our assessment of ens accountability for companies' stated action or company responses: inaction. 1. Public commitment 2. Health & safety We selected companies based on two criteria: 3. Accommodation 1) companies awarded contracts in Qatar and the 4. Recruitment UAE between 2014 and 2016, valued at at least 5. Contracts US$ 50 million and 2) companies involved in the 6. Payment infrastructure for the 2022 World Cup, Expo 2020 7. Freedom of movement Dubai and other mega-projects.8 In cases where 8. Worker voice the construction was awarded to joint ventures or 9. Grievance mechanism consortia we contacted all companies involved. 10. Subcontractor compliance

We adapted the survey based on the company’s main country of operations as per our selection criteria.

FINDINGS

Transparency

Of the 100 companies we contacted, only 22 To ensure comparability we have excluded the responded to our survey (17 construction frms, non-construction frms from the main analysis of 4 project management/engineering consul-tants the fndings, but have captured the key learnings and 1 developer). An additional company, from their responses in Box 1. Alstom9, is in the process of preparing a response and we welcome additional responses The table on the next page provides a snapshot from companies at any time. of what information companies provided and how much they disclosed in each area.

8 Qatar: World cup stadiums, Doha Metro and LRT, Lusail City, Education City, Msheireb, The Pearl Qatar, Doha Expressway and roads. UAE: Airports, Dubai Expo Rail Link ‘Expo 2020’, Dubai Parks & Resorts, Dubai Opera District, Dubai Creek Harbour projects, Saadiyat Island projects, MBR City, Habtoor City, Bluewaters, Palm Jumeirah. 9Alstom manufactures, installs and markets systems, equipment and services for the railway market. It operates in Qatar in a consortium with QDVC on the light rail transit LRT) project.

4 Accommodation Human rightsHealth & Safety Subcontractor Commitments Freedom ofWorker Voice Recruitment compliance Contracts Payments movement Grievance

Vinci

Multiplex

Salini Impregilo

Laing O’Rourke

Interserve

Carillion

Al Futtaim Carillion

SNC-Lavalin

TAV Construction

Aktor

Al Naboodah

Yapi Merzeki Insaat

QD-SBG

Sent a general statement

Besix

Hochtief

Bouygues

Van Oord

Not yet responded

Alstom Indicated it will respond

degree of relevant example of good Key: = information provided = practice in the in the answer information disclosed BOX 1 The human rights responsibility of clients and consultants

We contacted a number of developers and project management consultants to share information on their approach to migrant workers’ rights in their business relationships. There appears to be a gulf between clients and developers that have introduced worker welfare standards – Qatar Foundation, Qatar’s Supreme Committee for Delivery and Legacy, and Abu Dhabi’s Tourism & Investment Development Company – and those that view workers’ rights to bear no relation to their operations and/or as the sole purview of the principal contractor.

We found more of a spectrum of engagement among project management and engineering consultants. CH2M has developed a detailed worker welfare policy that is used to advise clients on international labour standards and applies to the company itself and all of the contractors in its supply chain. Atkins shared its ‘Minimum Requirement for Construction Safety’ and disclosed information on the firm’s approach to ensuring health and safety on the sites that it manages, but in answer to questions on recruitment, payment, grievance mechanisms etc. the company stated that it has “no responsibility nor influence in this area”. Parsons and Bechtel both have a public commitment to human rights and are members of the Global Reporting Initiative and the Global Business Initiative on Human Rights, respectively. Mace responded that the questions were not applicable to its business operations as a consultant.

What emerges is a mixed picture of understanding of the corporate responsibility for human rights among actors higher up the supply chain as well as varying levels of commitment to exert their sphere of influence. It is essential that these businesses become alert to their “moral duty not to collude in the exploitation of vulnerable people. Clients and principal contractors should take a responsible attitude to exploitation, even if they are not obliged to do so contractually. It’s all being done in their name, after all”.9

9 McMeeken, R., 2015. ‘Crossing the line’. Building. Available at: http://www.building.co.uk//5077183.article

6 Public commitment to human rights Carillion’s group-wide and regional MENA sustainability reports for 2015 both acknowledge the Thirteen (77%) of the 17 responding construction human rights risks in the company’s Qatar oper- firms have a public commitment to human rights ations and the measures that have been intro- in a stand-alone human rights policy or as part of duced to prevent and mitigate worker abuse. their sustainability and CSR policies, Codes of Conduct, or sustainability reporting. Other indications of public commitment to human rights include companies’ engagement with civil society and trade unions. Salini Impregilo has Looking at the wider sample of 100 companies, signed an international agreement with Italian and only 39% have expressed explicit human rights international construction unions to promote and commitments, which communicates a concern- respect fundamental human rights principles as ing lack of awareness or willingness to address defined by the UN, ILO and OECD. The company human rights that spans the sector. On the other participated in a meeting hosted by BWI on the end of the spectrum, several of the responding working conditions of migrant workers in Qatar companies have developed human rights/welfare and its worker accommodation has been visited policies and procedures specific to their by a BWI delegation. operations in Qatar and the UAE in recognition of the heightened human rights risks to their The chairman of Laing O’ Rourke has taken a migrant workforce in these countries. public stance on business leaders’ responsibility to tackle modern slavery, describing his com- As well as its public commitment to human rights, pany’s response to the discovery of exploitative Vinci (QDVC) has a Workers’ Welfare and Hu- recruitment practices in its supply chain in a 2015 - man Rights Policy specific to Qatar. The compa Huffington Post blog following the passing of the ny has also established a Human Rights Modern Slavery Bill. Commit-tee which includes the human resources directors of companies located in “potentially Other companies have demonstrated their com- sensitive regions.” mitment to ongoing improvement of their policies and procedures in the updates to their survey Multiplex has a Welfare Policy Statement and responses (Aktor, Carillion, Interserve and set of Welfare Principles, which the company’s Vinci (QDVC)) and through providing examples Middle East Executive Board ratified in Octo-ber of planned improvements, e.g. “the Company 2016. The company names 8 of the welfare plans to form a joint committee with principles in its survey response: 1. Employment representatives of its workforce and Joint Venture Standards, 2. Working Conditions, 3. Living management” (Yapi Merkezi Insaat, 2015). Conditions, 4. Recruitment Practices, 5. Access to Information and Documents, 6. Education and Training, 7. Fairness and Integrity, 8. Grievances and Labour Disputes. The company has simulta- neously instituted a ‘Welfare Management Sys- tem’ that includes audits to ensure that subcontractors, recruitment agents and accommodation facilities adhere to the Multiplex Welfare Policy and Principles.

7 Health and safety companies are transparent about worker deaths when they do occur. The health & safety (H&S) of migrant workers on construction sites is a serious concern given In the event of an injury, 8/17 companies (47%) the risk of injury and death associated with the confrmed the presence of trained medical per- hazardous work conditions. According to the ILO, sonnel on site. Vinci (QDVC) was the only com- construction workers are three to four times more pany to detail the steps it undertakes following an likely than other workers to die from accidents at incident. work. Deaths on World Cup sites have been the subject of intense contention and controversy. In 2013 the Guardian released devastating footage of coffins returning to Nepal from Qatar Although the substance and detail of the containing the bodies of construction workers. answers varied between companies, the responses clearly convey that there are A recent study assessing the cause of construc- accepted industry-wide policies and proce- tion accidents in the Gulf found that the most dures on health and safety that companies common types of worker accidents involved are expected to adhere to as a minimum. falling or being hit by objects, as is the case in The task for the industry and its advisors other parts of the world. The researchers pointed now is to build on the foundation that health to several factors that make occupational and safety certification provides and attach hazards worse in the Gulf, including inadequate the same importance and operational rigour training, limited use of safety equipment and to other aspects of migrant workers’ rights. weak en-forcement and regulation.

In the company responses we received, twelve (71%) of the companies referred to their H&S training programmes and eight (47%) made spe- Accommodation cific mention of providing workers with personal protective equipment. Fourteen companies (82%) reported being certified or audited in accordance The appalling living conditions of migrant con- with internationally-recognized H&S standards, struction workers in Qatar and the UAE have while 71% also reportedly carry out their own been the subject of media attention, prompting inspections. clients to introduce standards for worker accommodation that exceed the requirements of the Eleven (65%) of the responding companies pro- labour law (see Box 1). vided statistics on accidents and fatalities. Vinci (QDVC) reported two worker fatalities: a We asked companies what policies and proce- subcontracted worker in 2015, and a worker dures they have in place to ensure adequate employed by one of its JV partners on the Metro worker accommodation. Forty-seven percent Red Line South in 2016. Interserve’s subsidiary (8/17) described their approach, including regular Gulf Contracting Company also reported the audits and inspections by the company, meetings death of a worker employed by a subcontractor, with accommodation providers, comment boxes while QD-SBG reported a fatality in an off-site and/or convening of workers. Almost 60% (10/17) store area. reported being externally audited by government bodies, clients and/or civil society and indepen- While all companies should be working dent consultants. Besix, Salini Impregilo, and towards zero fatalities, it is important that Vinci (QDVC)’s worker accommodations have been visited by BWI.

8 BWI recommends that companies terminate their Al Futtaim Carillion reported that it relationships with recruitment agencies that vio- conducts “detailed reviews” of rental late these terms. accommodation in advance of contracting with landlords and performs regular Ten companies (59%) inferred some degree of audits to ensure standards are direct involvement in the recruitment process maintained. The company communicates (e.g. through in-country interviews, recruitment visits, spot checks etc.). Eleven companies (65%) workers’ concerns to accommodation stated that they have a no fee policy, but only 7 of providers at regular meetings and works these made explicit mention of bearing the cost of with them to implement necessary im- recruitment (i.e. employer pays principle). provements. Carillion also follows these procedures and has reportedly employed a Al Futtaim Carillion and Al Naboodah Con- dedicated team to audit new and existing struction Group’s responses indicate that there subcontractor staff accommodation. The are instances in which their employees pay some company stated that “should [subcontrac- of the expenses associated with recruitment, but tors] be unwilling to meet our required stan- that these amounts are capped. Employers are dards or make the necessary improvements expected to cover recruitment costs under UAE they are removed from our Project”. labour law, but payment of recruitment expenses by migrant workers may be permissable in their home countries.

Recruitment In cases where workers are found to have paid fees, fve companies - Laing O’ Rourke, Mul- Systems to recruit migrant workers are notorious- tiplex, Salini Impregilo, SNC-Lavalin and ly exploitative. Workers are frequently charged Vinci (QDVC) - referred to a policy of worker high recruitment fees by local employment reimbursement (either by the company or the agencies or agency intermediaries in their home recruiting agency). Six companies asserted that countries, often compelling them to take out they would terminate their business relationship/ high-interest loans or to sell their land and remove the agency from their preferred suppli- possessions to secure work. The resulting situa- er lists if found to be charging fees: Aktor, Al tion is one of debt-bondage, with workers unable Futtaim Carillion, Al Naboodah Construc- to negotiate fair pay or decent working conditions tion Group, Carillion, Salini Impregilo, Yapi at the risk of losing their sole source of income. Merkezi Insaat.

While companies alone cannot resolve the challenges associated with recruitment, they can take steps such as:

● Recruiting directly, or where that is not possible, employing recruitment agencies with established records in fair recruiting ● Ensuring workers do not pay any recruitment or placements fees ● Reimbursing fees to workers if they are found to have paid recruitment fees

9 Example of how companies are tackling exploitative recruitment

Employer pays principle

Laing O’Rourke asserted that it follows a rigorous and stringent process when identifying recruitment providers and requires them to uphold the standards set out in the company’s Code of Conduct. The company pays the recruitment fees directly to the agency as well as fights and pre-recruitment medical costs.

Contract clauses

Salini Impregilo stated that it includes specifc human-rights related clauses in its contracts with recruitment agencies, one of which prohibits charging recruitment fees.

Acting on due diligence

Vinci (QDVC) detailed the mechanisms it has introduced to prevent workers paying recruitment fees, following a detailed inquiry into the areas of vulnerability in its recruitment chain. These include:

● All advertisements in local newspapers mention a “free recruitment policy”, are featured in the workers’ native language, and are validated by the company beforehand. ● Workers are issued with a Workers’ Rights and Induction Booklet (available in English, Hindi and Bengali) during their recruitment, with information on the process, their rights and the living and working conditions at QDVC. ● The company’s service agreement with recruitment agencies prohibits the sourcing or pre- selection of candidates by anyone other than their own registered agents, and a temporary hotline is established so that candidates can communicate directly with the company recruitment officer. ● Workers are surveyed upon their arrival to verify they have not paid any fees, and the survey is repeated again after 3 and 6 month intervals.

In the event that workers have been “unrightfully charged”, Vinci (QDVC) mandates that the recruitment agencies reimburse expenses. Seventy-six of Vinci (QDVC)’s workers were reim-bursed fees in September 2016 as a result of these mechanisms.

10 Contracts Only four of the company responses referred to procedures currently in place to ensure that Another type of exploitation that takes place recruitment agencies and subcontractors comply during the recruitment process is contract with company policies regarding contracts: direct misrepresentation or substitution. In such cases, and comprehensive oversight (Laing O’Rourke), the terms and conditions of the contracts that prequalifcation criteria and penalties for violation workers sign in the country of destination difer (Interserve), contractual obligations (Salini Im- from the ofer they received before they migrated pregilo), audits (Vinci (QDVC) and Multiplex). and often entail much lower pay. Workers who have paid recruitment fees can therefore fnd themselves in situations akin to forced labour as Payment they have no option but to work for lower wages to meet their debt repayments. The UAE and Qatar have introduced Wage Pro- tection Systems (WPS) in recent years (2009 and Both the BWI and HRW guidance contain advice 2015 respectively) to address the issue of late for construction firms to counter this exploitative payment of wages and unauthorised deductions practice. The common elements are that: the from migrant workers’ salaries. The WPS is an contract should be provided to workers in a electronic payment system whereby the employer language they can read and understand, the sets up a personal bank account for each worker contracts should not be subject to modification on and transfers their salary into it on a monthly ba- the workers’ arrival in the country of destination, sis. The WPS transfers all records of payment to and companies should be involved in the the Ministries of Labour, enabling them to detect recruitment process either through direct hiring or salary delays and deductions and impose pen- diligent oversight of recruitment and labour alties on companies that fail to pay their workers supply agencies. their complete dues in a timely manner.

Ten companies (59%) said that they provide While the WPS has been a step forward in workers with a contract in a language that they regards to detection of wage violations, its pro- understand. Other companies like QD-SBG and tective capacity is less certain. In the wake of Yapi Merkezi Insaat only do so on request by the plummeting oil prices, governments and clients worker and Interserve indicated only doing so have been unable to pay contractors, the impact verbally. of which has reverberated down the contracting chain, leaving workers stranded without pay, Ten companies also stated or provided procedur- sometimes for months on end. In the most cat- al detail to the efect that workers’ contracts are astrophic case reported this year, foreign gov- not subject to modifcation on the workers’ arrival. ernments were compelled to step in to assist Aside from the companies that provided general thousands of stranded migrant workers in Saudi statements, the companies that did not mention a Arabia as Saudi Oger, one of the country’s big- policy or measures in relation to contract substitu- gest construction conglomerates, buckled under tion were Aktor and Yapi Merkezi Insaat. debt.

Vinci (QDVC) disclosed the provisions outlined According to their survey responses, 14 (82%) of in workers’ contracts, which cover “the promised companies pay workers according to national terms of remuneration; wages; hours of work in- legislation/WPS. Nine (53%) of the answers also cluding overtime entitlement; days of and annual made specifc reference to issuing personal bank leave; probation period; notice period and condi- cards to workers. Al Naboodah Construction tions for termination of each party.” Group and Al Futtaim Carillion have ATMs at their worker accommodation facilities.

11 Multiplex acknowledges the challenges associat- and/or exit visas on request. Minimal procedural ed with the timely payment of workers along the detail could be gleaned from the answers, but supply chain and stated that it has intervened in indications of better practice included reference to the past year to “ensure workers are adequately having a systematic procedure in place, providing compensated when a subcontractor has failed to NOCs with no conditions attached, and issuing pay wages” and to renew residency permits. exit visas on demand irrespective of the reason for departure.

The discrepancy between the broad adop- TAV Construction reported withholding workers’ tion of the Wage Protection System and passports for safekeeping and making them avail- the persistence of late/unpaid wages raises able to workers upon request. The remaining ma- pressing questions regarding the efficacy jority described a converse system to this, where- and enforcement of the WPS, the timely dis- by workers retain their own passports unless they tribution of payments along the contracting specifcally request in writing for the company to chain, and oversight of subcontractors’ pay- store them on their behalf. The latter practice is ment practices. The focus on the WPS also nominally acceptable, but relies heavily on the detracts attention from other critical wage assumption that companies have transparent, ac- issues, such as equal pay for equal work cessible and efcient procedures to return pass- (rather than on the basis of nationality). ports to workers on request. Where this is not the case, the result for the worker is much the same as having their passports withheld.

Freedom of movement Just two companies – Laing O’Rourke and Vinci (QDVC) – outlined a policy in which work- The Gulf’s kafala (sponsorship) system has been ers retain the sole custody of their passports. the subject of intense criticism for its potential to Both companies provide workers with personal trap migrant workers in abusive conditions. Under lockers/deposit boxes in their accommodation. In kafala, a migrant worker is tied to their kafeel the event that Vinci (QDVC) requires workers’ (sponsor) and requires their permission to trans- passports to process their residency permits, the fer employment and to obtain an exit visa to leave company provides workers with a photocopy of the country. There are no exit visa requirements their passport and a receipt that states the com- in the UAE.10 Coupled with the widely reported pany’s commitment to return the passports upon practice of passport retention, migrant workers completion of the application or renewal. can efectively be held captive by their employers.

Within this context, BWI specifes that companies should allow workers to change jobs should Worker Voice they choose to do so, should provide on demand exit-visas and no objection certificates (NOCs) to The formation of trade unions and freedom of employees wishing to leave the country, and association are restricted in Qatar and the UAE. should not confiscate or withhold workers’ This creates an additional challenge for migrant passports unless the worker agrees in writing and workers, already in a position of limited bargain- they have easy accessibility to their passports. ing power due to debt and insecure residence status, to assert their rights. Fifty-nine percent of the responding companies stated that they provide employees with NOCs

10 http://www.employmentlawalliance.com/Templates/media/fles/Immigration%20Overviews/Qatar_UAE.DOC

12 The HRW guidelines advise construction com- While the facilitation of migrant worker welfare panies to provide regular fora for migrant work- committees is a step in the right direction, ef- ers or worker representatives to discuss work fective curtailment of labour abuses requires and rights-related matters and concerns directly meaningful worker participation to identify risks with management. In our survey, only 47% of and abuse and contribute to solutions and en- responding companies made reference to work- forcement. The worker-driven social responsibility er fora distinct to health & safety committees. model, or WSR, provides a framework for worker The majority of the company responses did not organization that can be adopted by companies provide any detail on the operation of these fora, across their operations, and is practicable to a save to say that they existed and the types of degree in the Gulf context. issues discussed. Grievance mechanism In its response, Salini Impregilo wrote that it “seeks to give employees alternative The restrictions on freedom of association make means of expression. [The] Migrant Workers the provision of accessible grievance mech- Camp committee, formed by workers, res- anisms all the more important. HRW’s guide- idents’ representative and the heads of all lines recommend that companies establish “an Camp Departments, is in place to examine anonymous internal complaints process through which workers can lodge workers’ rights-related and discuss once a month issues of mutual concerns and ensure that they are aware of the concern. Input for discussion comes from process.” the suggestions, grievances or any other comments submitted by the workers through Eighty-eight percent (15/17) of responding com- the Comment Boxes available at all the panies indicated having some form of griev- Common Camp Areas. The Welfare Office ance mechanism in place for their workers. weekly collects, catalogues and records all The types of mechanisms referred to included the received messages, in order to be exam- grievance and comment boxes, whistle-blowing ined during the monthly meeting. hotlines/e-platforms, employee welfare committees and designated welfare ofcers or ‘grievance Aktor asserts that it Workers’ Advisory Com- receivers’, often in some combination. Sixty-fve mittee is “not precluded from collective bar- percent (11/17) reported having an anonymous gaining and the workers are not restricted channel for employees to submit grievances. from industrial action if they feel that their grievances are not being addressed”. Seventy-one percent (12/17) described how they communicated the mechanisms to migrant workers. Examples include verbal communica- tion through 1:1 meetings with supervisors or in The guidelines also call on companies to “re- various worker fora, notice boards and posters, spect workers’ rights to freedom of association handbooks and leaflets, explanatory films and and collective bargaining to the maximum extent multilanguage comment cards that explain how to permitted by national law.” Only fve companies submit grievances. cited a group-level policy on freedom of association in their responses, pointing to a worrying The company responses were weakest on their lack of commitment to migrant workers’ rights to descriptions of the procedures in place to address freedom of association and collective bargaining and remedy grievances and on preventing retalia- that extends beyond national legislation. tion against workers. Just four companies -

13 Laing O’Rourke, Multiplex, Salini Impregilo Subcontactor Compliance and Vinci (QDVC) - communicated a systematic procedure for addressing grievances once they were reported. “[O]ur business models must take a large part of the blame: the global trend towards outsourcing and cut price contracting makes Multiplex described its formal “Investigation it easy for main contractors to duck out of and Remediation Protocol” that prescribes their responsibilities. The plight of the most how the Welfare Team and operations staff vulnerable gets lost among the long and process, address and remedy a grievance. complex supply chains. It’s too convenient In order to create trust in the mechanism to blame the subcontractor or poor local and protect workers from retaliation the Wel- legislation. You might think that modern fare Team is “an independent functional slavery is not a problem where you work. department […] removed from the operation- Think again.” al delivery team members such as Supervi- sors etc.”. This quote from CIOB’s report ‘Modern Slavery: According to the company: “Upon receipt of a The Dark Side of Construction’ captures the high grievance, the Welfare Team will perform an risk of migrant worker abuse embedded in the assessment against a set of pre-determined long, fragmented and complex supply chains of risk factors to determine whether the construction companies. It also highlights the responsibility of main contractors and others at the grievance should be categorised as 1, 2 or 3. top of the supply chain to conduct human rights The resultant grievance categorisation then due diligence and ensure that human rights viola- determines which parties the grievance is tions are not occurring down their supply chains. escalated to and timescales for response.” As part of the protocol Employees receive BWI and HRW guidance mention several mech- information about what has been done to anisms for companies to ensure and enforce the remediate the grievance. rights of migrant workers hired by their subcontractors. These including legally binding worker- rights provisions in contracts, and requiring Vinci (QDVC)’s response outlined the company’s subcontractors to include similar provisions in practice of displaying Workers’ Welfare Commit- their own contracts, thereby cascading worker tee minutes in English and Hindi on notice boards welfare standards down the supply chain. on site, in the workers’ community and via email. The minutes record the issues raised, the solution We asked companies to describe the approach or whether the issues are still pending. they take to monitoring and enforcing their worker rights policies in their business relationships (e.g. Interserve, Laing O’Rourke, and Salini Impre- with recruitment agencies and subcontractors). gilo stated a policy of taking disciplinary action (including termination) in instances where work- Eighty-two percent of the companies articulated ers have faced retaliation for expressing griev- their expectations that subcontractors comply ances. with their standards and policies, and 65% provided indication of how they oversee subcontractor compliance in at least one key area e.g. audits and removal of violators from preferred suppliers lists.

14 Notably, procedures for monitoring subcontractors were most often mentioned in relation to ac- Interserve detailed the specifics of its new commodation and health and safety, but far less ‘Worker Welfare Procedure’: “We operate a so in the context of other critical areas such as prequalification process for our subcontrac- recruitment, grievance, wage payment, contract tors / suppliers which covers sustainability, substitution and passport retention. Only three health and safety, welfare, employment companies – Interserve, Multiplex and Vinci practices and management and supervision. (QDVC) - described clear, embedded procedures Failure to reach an acceptable score would across their operations vis-a-vis subcontractors. result in the subcontractor / supplier not prequalifying as would non-compliance with Besix and Hochtief pointed to their supplier any items noted as mandatory.” Post-qual- codes of conduct, which are contractually ification the company conducts audits and binding. Besix’s Sustainable and Responsible worker engagements to monitor subcontrac- Procurement Code of Conduct includes specific tor compliance on wage payment, accom- -lations on human rights, employment stipu modation, recruitment, provision of health- standards and health & safety. The company’s care, and preventing passport retention and suppliers and subcontractors are committed to contract substitution. The worker engage- comply with the company’s Code from the tender stage to com-pletion and is required to “fully and ment process also provides employees who transparently” participate in audits by the Besix do not work for the company directly with an Group, which can happen at any time. opportunity to raise concerns.

15 DISCUSSION OF THE CORPORATE RESPONSE

Transparency however, can not be resolved by companies acting in isolation: collective industry-wide efforts The most striking result of our survey was the are also needed. As it stands, the current lack of severe lack of transparency from the construction industry transparency limits the ability of companies we invited to respond. Only 22% of companies to tackle shared challenges and move forward together on the basis of agreed-upon the companies we contacted responded. In comparison, 80% of companies submit standards and good practice. responses when approached by the Centre to respond to human rights concerns raised by civil In 2015, the UAE launched the ‘Taqdeer Award’ to award construction frms for excellence in society. The response rates to our recent surveys labour relations. The initiative refects the import- of human rights risks facing clothing brands in ant awareness within the region of driving a race Turkey and of global renewable energy to the top by recognizing strong labour practices companies were 68% and 40%, respectively. and giving winners priority for future government projects. Beyond the survey, only 39% of the 100 companies have a available commitment to publicly Al Futtaim Carillion was the only Taqdeer Award human rights. Just 3 have a policy that explicitly winner to respond to our survey. It is disappoint- references the protection of migrant workers. This ing that the other Taqdeer Award companies that lack of commitment is alarming given the wide- we contacted - Arabtec, BK Gulf, Dutco Balfour spread exploitation and abuse faced by the large Beatty, Habtoor Leighton Group and United numbers of migrant workers employed in the Engineering Construction – did not respond. construction industry globally, and in Qatar and the UAE in particular. It is particularly disconcerting seeing as several of the Award winners have been linked to al- The current wage crisis that is sweeping Gulf legations of migrant worker abuse in the past: countries proves that companies cannot rely on Arabtec and Habtoor Leighton Group were national legislation or the operational status quo featured in a 2009 Human Rights Watch report to protect migrant workers’ rights. In the wake of on migrant labour exploitation on Abu Dhabi’s plummeting oil prices, governments and clients Saadi-yat Island and BK Gulf (a subsidiary of have been unable to pay contractors, impacting Balfour Beatty) was recently linked to subcontractors and workers down the supply allegations of worker abuse in Qatar. The chain. Furthermore, the widespread and nominal- companies respond-ed to the allegations at the ly acceptable practice of retaining worker pass- time (follow links). ports for safe-keeping has failed to protect workers when companies have become embroiled The lack of public disclosure from this group of in debt. Recent instances of stranded workers companies is a squandered opportunity to across the Gulf (Qatar, UAE, Saudi Arabia, Bah- showcase the actions they are taking that rain, Kuwait and Oman) abandoned without pay, purportedly merit recognition and to share best accommodation and food, sometimes for months practice for others to follow suit. on end, are a clear demonstration that current worker protections are wholly inadequate. Impetus There is a small group of forerunners that have disclosed meaningful information on their policies A clear and urgent challenge is how to incentivise and procedures to protect migrant workers in companies in all regions to take a their Gulf operations. The risks inherent in accepted business models and complex supply chains, 16 responsible approach to the recruitment and so that they retain exclusive custody of their employment of migrant workers and to report on passports. those steps. Vinci (QDVC) touches on this in its 2016 survey response: “QDVC operates in a That said, implementing the corporate respon- highly competitive market. Unfortunately, some sibility to respect human rights is a continuous competitors do not take these issues into consid- process and one that takes time, and the con- eration when conducting their own operations, struction sector is only at the start of the road. In thus placing QDVC in a challenging position. responding to the risks of exploitation in its com- [Changes are needed] to help compliant contrac- plex supply chains it can draw important lessons tors to remain competitive and create positive from sectors that have long been scrutinized, incentives for the rest of the industry.” such as the apparel, food and electronics industries. Furthermore, companies’ existing Some of the push factors for responsible action commitments to health and safety throughout can be drawn from the examples of pioneering their supply chains, and the understanding and companies: Salini Impregilo’s engagement with broad adoption of accompanying standards and international and Italian trade unions has led to certification, provides a foundation for companies a global commitment to protect and respect the to make progress in other areas of workers’ human rights of its employees, while Laing O’Ro- rights. urke’s leadership has expressed public support for the Modern Slavery Act and embraced the re- The restrictions on migrant workers’ rights to sponsibility of business leaders to confront mod- freedom of association and collective bargaining ern slavery in their supply chains. Carillion and and weak access to remedy is a critical challenge Interserve similarly cite the Act as a catalyst for for companies. Few of the survey responses action in their most recent sustainability reports. communicated clearly defined, formal procedures to educate workers on company welfare policies In addition to binding commitments and man- and labour rights or to process individual and datory transparency, independent scrutiny from collective grievances in a transparent, predictable civil society, media and industry experts is also and accountable manner. It is critical that an essential catalyst for change. Both Carillion companies explore ways to engender meaningful and Interserve have been at the centre of recent worker participation in line with international media reports documenting cases of migrant labour standards and, in-so-far as possible, a worker abuse tied to their Qatar operations. In worker-driven social responsibility model. 2015, the NGO Sherpa fled a complaint against Vinci (QDVC) in a French court, alleging forced Concluding remarks labour in the company’s Qatar operations. Vinci (QDVC) fled a defamation lawsuit against Sherpa The survey responses, although scarce in num- in response. ber, clearly demonstrate that the construction industry is aware of the risks to vulnerable migrant What is clear from these examples is that driving workers in its supply chain and is exploring ways progress on human rights across the industry re- to prevent exploitation. quires a multi-stakeholder approach that includes governments, intergovernmental organisations, Now is the time for companies with poor disclo- companies and their business partners, civil soci- sure to emerge from behind their wall of silence ety, trade unions, journalists and other concerned on human rights. The sector might have entities. previous-ly escaped the scrutiny of consumer- facing sec-tors, but that is no longer the case. Action The attention to the human-rights performance of the construc-tion industry spurred by the Qatar Our outreach to companies identifed examples World Cup has resulted in a concerted focus on of action for the rest of the industry to heed and the sector and its business partners from follow. Among these are short-term steps that international institutions, governments, media companies can take to have an immediate impact and civil society. These actors will continue to on migrant workers’ rights such as installing per- shine a spotlight where the industry refuses to do sonal safes for workers in their accommodation so.

17 RECOMMENDATIONS

Companies should:

● Adopt a policy commitment to human rights. This should include a specifc commitment to upholding international standards on the protection of migrant workers. ● Conduct robust due diligence and monitoring to identify vulnerable workers and the risks they face, including through business relationships. ● Implement clear processes to protect migrant workers from exploitation, including urgent action to:

o Ensure workers retain sole custody of their passports o Adopt the employer pays principle for recruitment throughout supply chains and engage in direct hiring of workers as far as possible o Prevent worker deaths and publicly report injuries and fatalities o Guarantee the contract offered to workers in their countries of origin and prevent contract modification o Ensure all workers are paid on time and in full, and enforce subcontractors’ compliance with the wage protection system

● Ensure protection for workers throughout the supply chain: regulate relationships with suppliers and subcontractors through workers' rights-related clauses in bidding/prequalification documents and contracts. ● Enable meaningful worker participation, looking to worker-driven social responsibility approaches as an example. ● Establish grievance mechanisms in line with the UNGP’s effectiveness criteria, designed with worker input and with robust protection from retaliation. ● Establish an industry group, with strong mechanisms for civil society input, to identify risk, share challenges and good practice, develop guidance and push for pre-competitive industry wide standards.

Governments and clients should strengthen the pre-competitive advantage and incentives for construction firms to take a responsible approach to the recruitment and employment of migrant workers e.g. through mandatory transparency and due diligence requirements as well as reforms to the ten- dering process.

Advisors, lawyers and consultants should promote a transparent and effective approach to the protection of migrant workers’ rights.

Investors should reward companies that demonstrate transparency and due diligence.

Media, civil society and advocates should:

● focus attention on laggards and recognize the efforts of leaders to prevent and tackle migrant worker abuse. ● work to improve documentation of migrant worker abuse by construction companies, and highlight discrepancies between policy and practice.

18 COMPANY RESPONSE HQ Human rights commitment UN Global Compact Responders Aktor Response Greece No Yes Al Futtaim Carillion Response UAE Yes No Al Naboodah Construction Group Response UAE No No Atkins (PMC) Response UK Yes No Bechtel (PMC) Response USA Yes No Besix Response Belgium Yes Yes Bouygues Response France Yes Yes Carillion Response UK Yes Yes CH2M (PMC) Response USA Yes Yes Hochtief Response Germany Yes Yes Interserve Response UK Yes No Laing O’Rourke Response UK Yes No Multiplex Response UK Yes No Parsons (PMC) Response USA Yes No QD-SBG Construction Response Qatar No No Salini Impregilo Response Italy Yes Yes SNC-Lavalin Response Canada Yes Yes TAV Construction Response Turkey No No TDIC (Developer) Response UAE No No Van Oord Response Netherlands No No Vinci Response France Yes Yes Yapi Merkezi Insaat Response Turkey No No Preparing a response Alstom Preparing a response France Yes Yes Non-responders Acciona Non-response Spain Yes Yes Actco General Contracting Non-response UAE No No Al Ali Engineering Non-response Qatar No No Al Balagh Trading & Contracting Non-response Qatar No No Al Darwish Engineering Non-response Qatar No No Al Habtoor Group (Developer) Non-response UAE No No Al Jaber Group Non-response UAE No No Al Mansouri 3B Non-response UAE No No Al Shafar General Contracting Non-response UAE No No ALEC Non-response UAE No No Ali & Sons Non-response UAE No No Arabian Construction Company Non-response Lebanon No No Arabtec Construction Non-response UAE No No Archirodon Non-response Greece No No Balfour Beatty Non-response UK Yes No Bam International Non-response Netherlands Yes No Bin Omran Trading & Contracting Non-response Qatar No No China Harbour Engineering Company Non-response China No No China Railway 18th Bureau Group Non-response China No No China State Construction Engineering Corporation Non-response China No No Cimolai Non-response Italy No No Cimolai Rimond Non-response Italy No No Consolidated Contractors Company Non-response Greece Yes Yes Constructora San Jose Non-response Spain Yes No Daewoo Engineering & Construction Non-response South Kor ea Yes Yes Dogus Insaat Non-response Turkey No Yes Drake & Scull International Non-response UAE No No Dubai Parks & Resorts (Developer) Non-response UAE No No El Seif Engineering & Contracting Non-response Saudi Arabia No No FCC Non-response Spain Yes Yes Ferrovial Non-response Spain Yes Yes Fujairah National Construction Company Non-response UAE No No Galfar Al Misnad Non-response Qatar No No GS Engineering & Construction Non-response South Korea Yes Yes Gulermak Non-response Turkey Yes No Habtoor Leighton Group Non-response UAE No No HBK Contracting Non-response Qatar No No Hyundai E&C Non-response South Korea Yes Yes J&P Avax SA Non-response Greece No No Joannou & Paraskevaides (Overseas) Non-response UK No Yes Khansaheb Non-response UAE No No Kier Non-response UK Yes No Larsen & Toubro Non-response India Yes No Lotte E&C Non-response South Korea Yes* No Mace *NB: PMC Non-response UK No No Medgulf Non-response Qatar No No Meydan Sobha (Developer) Non-response UAE No No Midmac Non-response Qatar No No MS Construction Non-response UAE No No NSCC International Non-response UAE No No Obayashi Non-response Japan Yes Yes Oger Abu Dhabi Non-response UAE No No OHL Non-response Spain Yes Yes Onur Non-response Turkey No No Orascom Non-response Egypt Yes No Petroserv Non-response Qatar No No Pivot Engineering & General Contracting Non-response UAE No No Porr Non-response Austria Yes No Punj Lloyd Non-response India No No Qatar Building Company Non-response Qatar No No Redco International Non-response Qatar No No Rizzani de Eccher Non-response Italy No No Samsung C&T Non-response South Korea No No Shapoorji Pallonji Non-response India No No SK Engineering & Construction Non-response South Korea Yes Yes Ssangyong Engineering and Construction Non-response South Korea No No Starneth Engineering Non-response Netherlands No No STFA Non-response Turkey Yes No Taisei Corporation Non-response Japan Yes No Tefken Construction Non-response Turkey Yes No Teyseer Group Non-response Qatar No No Tristar Engineering & Construction Non-response UAE No No Trojan Holding Non-response UAE No No United Engineering Construction Non-response UAE No No Wade Adams Non-response UAE No No WCT Holdings Non-response Malaysia No No Yuksel Non-response Turkey Yes Yes Key: * Commitment in sustainability report Annex 1

International standards

● UN Guiding Principles on Business and Human Rights ● OECD Guidelines for Multinational Enterprises ● ILO Declaration on Fundamental Principles and Rights at Work ● ILO Core Conventions ● The Dhaka Principles for Migration with Dignity (Institute of Human Rights and Business, 2016)

Guidance and resources

● Amnesty International, 2016, The Ugly Side of the Beautiful Game: Exploitation of Migrant Workers on a Qatar 2022 World Cup Site. ● BSR, 2016, Addressing Workers’ Rights in Engineering and Con struction: Opportunities for Collaboration. ● BWI, 2014, Decent Work for Migrant Workers in Qatar: Role of Con struction Companies. ● CIOB, 2016, Building a Fairer System: Tackling Modern Slavery in Construction Supply Chains. ● Engineers Against Poverty, 2014, Improving Employment Standards in Construction in Qatar. ● HRW, 2015, Guidelines for a Better Construction Industry in the GCC: A Code of Conduct for Construction Companies. ● ILO, 2016, Ways Forward in Recruitment of Low-skilled Migrant Workers in the Asia-Arab States Corridor. ● ITUC, 2015, Frontlines Report 2015, Qatar: Profit and Loss – Count ing the Cost of Modern Slavery in Qatar: What Price is Freedom? ● LexisNexis, 2016, Hidden in Plain Site: Modern Slavery in the Con struction Industry. ● Verité, 2016, An Exploratory Study on the Role of Corruption in International Labor Migration.

20 Business & Human Rights Resource Centre is an international NGO that tracks the human rights impacts (positive & negative) of over 6900 companies, making information available on its nine-language website.

We seek responses from companies when concerns are raised by civil society. The response rate is over 80% globally.

We encourage companies that have not yet completed our survey to submit a completed response. If any company would like to send us additional information, it is welcome to do so at any time.

For more information on our work on migrant rights in the Gulf contact the author of this brief- ing: Mariam Bhacker, Project Manager: bhack- [email protected]